Civil Rights

Feeney v. Massachusetts — Study Notes

442 U.S. 256 (1979)

Study notes for Feeney v. Massachusetts: professor notes, cold call prep, exam angles, and memory aids.

A law granting preference to veterans does not violate the Equal Protection Clause unless intent to discriminate can be proven.
Professor Notes

In Feeney v. Massachusetts, the Supreme Court addressed the complexities of the Equal Protection Clause in the context of employment discrimination. The case revolved around a Massachusetts statute that prioritized veterans for state civil service positions, which disproportionately impacted women. Professors emphasize the distinction between laws resulting in disparate impact and those reflecting intentional discrimination, with the Court ruling that mere statistical disparities do not equate to unconstitutional action without proof of discriminatory intent.

Another critical point often highlighted is the Court's reliance on historical context and legislative intent. The ruling underscores the importance of evaluating the intentions behind statutes when assessing claims under the Equal Protection Clause. It compels students to consider how protective legislation for one group may unintentionally disadvantage another, raising vital discussions about equity versus equality in public policy.

Cold Call Prep
  1. 1What was the main legal question in Feeney v. Massachusetts?
  2. 2How did the Supreme Court interpret the Equal Protection Clause in this case?
  3. 3What evidence did the Court rely on to determine the absence of discriminatory intent?
  4. 4Can you explain the significance of disparate impact versus discriminatory intent as established in this case?
  5. 5How does this case relate to discussions about affirmative action?
  6. 6What implications does the Court's ruling have for future legislation aimed at benefiting specific groups?
  7. 7What are some potential criticisms of the Court's interpretation of this statute?
Mnemonic Device

Vets Favor Male: Veterans' preference laws favor men, but are not inherently discriminatory without intent.

Distinguish From
CaseDistinction
Washington v. DavisIn Washington v. Davis, the Court emphasized the necessity of proving discriminatory intent, which aligns closely with Feeney's emphasis on intent over impact.
Grutter v. BollingerIn Grutter, the Court upheld affirmative action policies that explicitly aimed to address past discrimination, contrasting with Feeney's statute that lacked such intent.
McCleskey v. KempMcCleskey involved statistical evidence of racial disparities in capital sentencing, where the Court found that the evidence did not demonstrate intentional discrimination, similar to Feeney's analysis of intent versus impact.
Policy Arguments

For the Rule

The veterans' preference law promotes a legitimate government interest in recognizing the sacrifices of military service members, which may justify the disparate impact.

Against the Rule

Such preferences may perpetuate systemic inequality by disadvantaging qualified women and concealing underlying gender biases.

Class Discussion Points
  • How do we balance the interests of affirmative action with equal protection principles?
  • What role does historical context play in evaluating the constitutionality of employment preferences?
  • Can statutes designed to benefit one class inadvertently harm another, and what implications does this have for legislative practice?
Exam Angle

Feeney v. Massachusetts often serves as a key case when discussing the Equal Protection Clause, particularly in distinguishing between intentional discrimination and disparate impact. Students may be asked to analyze statutes in terms of their intent and impact on protected groups.

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